Radio spots and spoken promotions for medical treatments and services in Poland

Healthcare activity: factual information must not become advertising

Legal requirement — paraphrased

Applies when: The message concerns healthcare activity; this is conditional for diagnostics, digital health, aesthetic procedures and wellness.

Where the offer is healthcare activity, Article 14 requires public information about the scope and types of services, while prohibiting advertising characteristics in its content and form. This applies to registered providers and professional practices; payment for a placement does not remove the restriction.

Editorial approach: start with identity, actual qualifications, service scope, location, access and neutral practical information. Have persuasive slogans, superiority claims, discounts and urgency devices assessed against the statutory restriction; do not present them as routinely permitted.

Sources: Healthcare Activity Act — consolidated text, Dz.U. 2026 item 156 · Article 14

Doctors and dentists also have professional obligations

Legal requirement — paraphrased

Applies when: A doctor or dentist is involved; other professions require their own professional-code check.

The code effective since January 2025 permits information about offered services subject to ethics and makes doctors responsible for third-party information issued on their behalf. It does not displace Article 14 of the Healthcare Activity Act.

Use only earned titles and qualifications, avoid misleading accounts of competence or costs, and do not exploit medical authority to promote unrelated services. These requirements apply to public internet and media activity too.

Sources: NIL — Code of Medical Ethics effective from 1 January 2025; Healthcare Activity Act — consolidated text, Dz.U. 2026 item 156 · Code Articles 70–71, 73 and 78; Healthcare Activity Act Article 14

Describe a treatment without promising an individual outcome

Editorial recommendation

Editorial review should distinguish a procedure's purpose, eligibility, limitations and possible follow-up from a promise of success. Testimonials and success percentages need context and evidence; a consultation remains an individual clinical assessment.

If the message promotes a device-based service, apply the additional device-service branch. If it promotes a named prescription medicine, stop and apply the public Rx restriction.

Sources: Healthcare Activity Act — consolidated text, Dz.U. 2026 item 156; Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845; Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620; Pharmaceutical Law — consolidated text, Dz.U. 2026 item 612 · Healthcare Activity Act Article 14; Device Act Article 58; Pharmaceutical Law Article 57

Device-based services can trigger a second advertising regime

Legal requirement — paraphrased

Applies when: The message advertises a device-based service within Article 58; assess the exact creative.

Device-advertising rules extend to business/professional services to the extent they concern services provided using a device, including rental. They also cover remunerated user opinions. A clinic's own account and a paid creator are not exempt.

Before showing equipment or device-based treatment benefits publicly, assess the lay-user restriction and healthcare-professional presentation restriction. For qualifying public advertising, check the identity, warning and format requirements in the device advertising regulation. Ordinary service information is not automatically device advertising.

Sources: Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620; Medical-device advertising regulation — Dz.U. 2023 item 817 · Device Act Article 58(1); advertising regulation sections 2–4

Include device identity and the correct Polish warning

Legal requirement — paraphrased

Applies when: The exact message is public device advertising, including qualifying device-based service advertising under Article 58.

Apply this module only to qualifying public device advertising, including a device-based service falling within Article 58. It does not make an otherwise prohibited advertisement permissible.

For public device/IVD advertising, identify the advertiser, manufacturer and appointed authorised representative, alongside device name and intended purpose. The warning is: To jest wyrób medyczny. Używaj go zgodnie z instrukcją używania lub etykietą.

For Annex XVI non-medical-purpose products and device accessories, the regulation instead specifies: Dla bezpieczeństwa używaj zgodnie z instrukcją używania lub etykietą. Determine the correct branch before drafting.

Sources: Medical-device advertising regulation — Dz.U. 2023 item 817; Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620 · Sections 1–3

Fit device warnings to image, audio or video

Legal requirement — paraphrased

Applies when: The exact message is public device advertising, including qualifying device-based service advertising under Article 58.

Apply this module only to qualifying public device advertising, including a device-based service falling within Article 58. It does not make an otherwise prohibited advertisement permissible.

Audiovisual: warning in the bottom 15% or more, clearly spoken in Polish for at least four seconds. Audio: at least four seconds of clear Polish warning. Visual: bottom 10% or more, on the first page of multipage advertising. Observe the prescribed contrast, static horizontal text and spacing.

Sources: Medical-device advertising regulation — Dz.U. 2023 item 817; Medical Devices Act — consolidated working text based on Dz.U. 2024 item 1620 · Section 3(3)

Protect patients before using stories, images or testimonials

Editorial overview

Applies when: Patient information or identifiable treatment material is used.

Do not assume treatment consent authorises a public case study, testimonial or before/after photograph. Check confidentiality, privacy and a separate lawful basis for the proposed disclosure, including health data; public responses to reviews must not reveal confidential treatment details.

Editorial safeguard: obtain a specific, voluntary publication permission for the intended material and channels, assess identifiability even when the face is hidden, and check that refusing publicity does not affect care. Publication permission cannot cure unlawful advertising or misleading outcome claims.

Sources: Patient Rights Act — consolidated text, Dz.U. 2024 item 581; Regulation (EU) 2016/679 — General Data Protection Regulation · Patient Rights Act Articles 13–14 and 20; GDPR Articles 5–7 and 9

Review information published by the clinic and its agency

Regulator guidance

Applies when: The practitioner is a doctor or dentist; do not extend this code automatically to other professions.

NIL explains that a doctor’s responsibility includes information commissioned from others and information published on the doctor’s behalf. Review descriptions of the doctor on the employer’s website as well as agency and creator materials.

The commentary warns against aggressive or misleading communication that promotes inappropriate treatment. This professional guidance supplements the statutory healthcare-information restrictions.

Sources: NIL — Commentary on Article 71: information about offered services

Make the overall message truthful and commercially identifiable

Legal requirement — paraphrased

Misleading claims, material omissions, hidden commercial intent and aggressive consumer marketing are prohibited. Assess visuals, comparisons, qualifications and the impression on vulnerable consumers. Do not falsely claim that a product cures illness.

Editorial control: retain substantiation before publication, remove fabricated urgency or authority badges, and check that qualifications do not contradict the headline. Paying to publish apparently independent advice must not conceal its commercial nature.

Sources: Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845 · Articles 4–9; Article 7 hidden advertising and false cure claims

Check price reductions only after establishing that promotion is lawful

Legal requirement — paraphrased

Where an advertisement announces a reduction for a good or service, state the relevant lowest price from the preceding 30 days alongside the reduced price. For a shorter selling history, use the lowest price since sales began; special rules apply to rapidly perishable goods.

This consumer-information rule does not permit a discount or purchasing incentive prohibited by medicine or service rules. As an editorial check, make the total scope and extra charges clear.

Sources: UOKiK — Information about price reductions · Price Information Act Article 4 as explained by UOKiK

Keep reviews genuine and explain verification

Legal requirement — paraphrased

Do not publish, commission or distort false consumer recommendations. If making consumer reviews available, explain whether and how their origin is verified. Do not claim authentic-user verification without reasonable, proportionate checks.

Selecting a patient or customer story for advertising also requires checking the sector's claims and endorsement restrictions. A genuine testimonial can still contain an unlawful health claim.

Sources: UOKiK — False reviews? Stop!; Act on Counteracting Unfair Market Practices — consolidated text, Dz.U. 2023 item 845 · Unfair-practices Act Articles 6–7; UOKiK reviews guidance

Broadcast advertising adds separation, sponsorship and placement rules

Legal requirement — paraphrased

Commercial communications must be recognisable; hidden or subliminal advertising is prohibited. Advertising of healthcare services available exclusively on a doctor's referral is prohibited in the broadcasting regime. Product and provider restrictions apply in addition.

Sponsorship and product placement have separate conditions and cannot be used to bypass prohibited advertising. Have the broadcaster classify the execution and check the applicable restrictions, rather than treating a sponsorship ident as a normal ad slot.

Sources: Broadcasting Act — consolidated text, Dz.U. 2022 item 1722 · Articles 16, 16b–16c, 17 and 17a

Allow enough airtime for required spoken content

Editorial recommendation

Medicine and device warnings use different prescribed lengths; apply the relevant sector module rather than a universal health disclaimer. Include required product information clearly and assess the full voiceover, endorsement and sponsor treatment.

Recommended production check: time the final recording, listen for clarity at ordinary playback speed, and remove claims that become misleading without the visuals used in another version of the campaign.

Sources: Medicine advertising regulation — consolidated text, Dz.U. 2023 item 1648; Medical-device advertising regulation — Dz.U. 2023 item 817 · Medicine regulation section 8; device regulation section 3

Keep one campaign evidence and approval record

Editorial recommendation

Recommended workflow: record the exact offer and legal classification, advertiser, selected channel and creative formats; list permitted claims and evidence; review the Polish execution and destination; record sign-off, publication and corrections.

Keep the source date with the rule. Recheck legislation flagged as changing, especially pharmacy advertising. Preserve statutory archive periods where they apply; this suggested general workflow does not create a universal retention period.

Sources: URPL — Advertising medical devices; Sejm official API — Pharmacy advertising amendment, process 3002 · Specific retention and legislative-watch sources; workflow is editorial